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List Account for November 29, 1986, reveals that petitioner
purchased casino chips in the amounts of $1,000, $1,700, $2,100,
$800, $300, $1,800 and $3,000, which corresponds with the $10,700
shown on the CTR for that date. Thus, the dollar figures on the
List Account for May 19, 1985, and November 29, 1986, corroborate
the dollar figures shown on the CTR's filed by Tropworld.
Petitioner does not dispute the evidence presented by
respondent concerning the purchase of the casino chips on May 19,
1985, and November 29, 1986. Petitioners argues that respondent
had a duty to obtain records from Tropworld that would reveal
petitioner's gambling winnings during 1982 and 1983 and that, by
failing to do so, respondent's opening cash on hand figure is
fatally flawed. This argument is without merit. Respondent need
only establish, with reasonable certainty, petitioners' net worth
as of January 1, 1984. Any gambling winnings from 1982 and 1983
will be taken into account in the net worth calculations.
Petitioners reported no gambling winnings on any tax returns
filed for the years 1982 through 1986.
We find that petitioner incurred nondeductible expenditures
of $13,100 on May 19, 1985, and $10,700 on November 29, 1986, for
the purchase of casino chips at Tropworld.
We conclude that respondent's net worth computations meet
the first prong of the test in Holland v. United States, 348 U.S.
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